The New York State Tax Appeals Tribunal has upheld an Administrative Law Judge decision holding that a company that provided security guard services subject to sales tax failed to prove that it relied in good faith on exemption certificates received from customers. Matter of Crown Security, LLC, et al., DTA Nos. 824873 & 824957 (N.Y.S. Tax App. Trib., July 2, 2015). The exemption certificates produced by the company were found to be incomplete and, in all but one instance, identified the purchase of tangible personal property rather than security services. The Tribunal also held that since the company had been advised during a prior sales tax audit that its services were subject to sales tax, it could no longer rely “in good faith” on exemption certificates.